Cookie and Privacy Policy

K.COM PRIVACY AND COOKIE NOTICE

1. Introduction

Effective Date: June 15, 2018

We at Krece, a division of Macmillan Publishing Group, LLC (“K,” “we” or “us”) respect your concerns about privacy and value the relationship we have with you. This Privacy and Cookie Notice applies to personal information we collect through any online interface (e.g., website, mobile application, or other interactive service) that contains a link to this Notice authorized by us (the “Site(s)”). This Notice also applies to personal information we receive outside of our Sites, e.g., information we receive at trade shows, business meetings or through publicly available websites or publications.

This Privacy Notice describes the types of personal information we collect, how we may use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to safeguard the information and tell you how to us about our privacy practices.

European Union (EU) Individuals only: if you are in the EU, when we use personal data about you related to us offering you products or services or where we follow your actions within the EU (“EU Processing”) we will do so as relevant EU law allows including by providing further information about that EU Processing in the sections of this Privacy Notice marked "Note to EU Individuals only". Subject to those sections, the rest of this Privacy Notice still applies to you but these sections do not apply to anyone else.

We may obtain certain personal information (such as name and other details) when you choose to provide it to us, when it is publicly available, automatically from our Sites or from third parties. The types of personal information we may collect include:

information provided at conferences or other places, such as on business cards or through conference badge swipes and from public websites or other publicly available sources.

In addition, when you visit our Sites, we may collect certain information by automated means, such as cookies and web beacons. The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our Sites, and dates and times of visits to the Sites. By collecting this information, we can better understand activity on our Site learn how to best tailor our Sites to our visitors. While we generally examine such information only in the aggregate, such information could be linked back to individual IP addresses or other information about you. For more information on cookies, see the next section.

Note to EU Individuals only: We will only retain your personal data obtained through EU Processing for as long as necessary to fulfil the purposes of use, see the How We Use The Information We Collect section below, including as necessary for addressing any legal, accounting, or reporting risks or requirements related to them, for example the limitation period for which legal claims can be made in court and archival purposes. To determine the appropriate retention period for personal data, we also consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes of use and whether we can achieve those purposes through other means.

Note to Canadian Individuals only: We retain personal information for as long as necessary to fulfil the purposes for which it was collected, or to otherwise meet a valid legal or business requirement or need.

3. Cookies and Online Tracking

A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. We use two kinds of cookies on the Sites: session cookies and persistent cookies. Session cookies exist only for as long as your browser remains open. Once you exit your browser, they disappear. Persistent cookies, in contrast, last from visit to visit; they remain on your hard drive after you exit your browser. The cookies used on the Sites include those which are strictly necessary cookies for access and navigation, cookies that track usage (performance cookies), remember your choices (functionality cookies), and cookies that provide you with targeted content or advertising (described more below under “Interest-based Advertising”). Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Sites.

We may use the information we obtain from your use of our cookies for the following purposes:

to recognize your computer when you visit the Sites;

to track you as you navigate the Sites, and to enable the use of any e-commerce facilities;

to improve the Sites’ usability;

to analyze the use of the Sites;

in the administration of the Sites; and

to personalize the Sites for you, including serving targeted advertisements which may be of particular interest to you both on and off the Sites.

We also may use “web beacons” on our Sites. A web beacon, also known as a pixel tag or clear GIF, may be used to transmit information collected through cookies back to our service providers’ servers. These web beacons are the technique by which our service providers compile information about your browsing activity on the Sites.

Interest-based Advertising

We may collect information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. This section of our Privacy and Cookie Notice provides details and explains how to exercise your choices.

You may see certain ads on other websites or in your emails based on your visits to our Sites and third-party sites because we participate in advertising networks administered by third-party vendors, such as Google AdWords. Ad networks allow us to target our messaging to users considering demographic data, users’ inferred interests and browsing context. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs and web beacons. The networks use this information to show you advertisements that are tailored to your individual interests, to track your browser across multiple websites, and to build a profile of your web browsing. The information our ad network vendors collect includes information about your visits to websites that participate in the vendors’ advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Sites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

Some of our advertising and content partners that may access and use cookies and other data through our Sites are set out below with information about their privacy and opt-out practices. You can also delete and/or block specific cookies from your browser (as explained above):

("Google"): allows us to monitor how visitors use our sites and also allows us to serve personalized ads which uses personal information such as, but not limited to, geolocation, in order to serve the user ads on non K Sites. For more information on their privacy practices and their use of cookies, please see . To opt-out, see .

("Amazon"): allows us to serve users personalized ads which use personal data based on browsing behavior on our sites. For more information on their privacy practices and their use of cookies, please see . To opt-out, see .

("Undertone"): delivers advertisements and ad related services and uses technical information about the user, including but not limited to the type of device, operating system, or browser. For more information on their privacy practices and their use of cookies, please see . To opt-out, see .

(“Facebook”): allows us to serve users personalized ads which uses personal data based on browsing behavior on our sites. For more information on their privacy practices and their use of cookies, please see and .

(“Exact Target”): allows us to email users personalized ads which uses personal data based on browsing behaviors on our sites. For more information on their privacy practices and their use of cookies, please see .

("OpenX"): provides demographic and browser information as well as user device information, location data, and ad reporting data. OpenX uses personal, technical, and browsing data of the user. For more information on their privacy practices and their use of cookies, please see . To opt-out, see .

("DistroScale"): provides editorial or sponsored content as videos on K sites. DistroScale uses device type and country geolocation data of the user to provide its services. For more information on their privacy practices and their use of cookies, including how to opt-out, please see .

(“ZergNet”): provides content recommendation which collects and uses data such as IP address, user’s browser and device information, and browsing history. For more information on their privacy practices and their use of cookies, including how to opt-out, please see .

You can also obtain more information about interest-based advertising, and how to opt-out of receiving interest-based ads from participating third-party providers and ad networks, through the following:

Opting out of participating providers and ad networks does not opt you out of being served advertising. If you opt-out, we will not send you targeted ads based on behavioral information we or our partners have obtained about you, but you may continue to receive generic or contextual ads on our Sites.

To successfully opt-out, you must have cookies enabled in your web browser. Please see your browser’s instructions for information on cookies and how to enable them. Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each device that you use. Once you opt out, if you delete your browser’s saved cookies, you may need to opt-out again.

Analytics

We also use third-party web analytics services on our Sites, such as Google Analytics. These service providers help us analyze how users use our Sites. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. These service providers may retain and use non-personally identifiable collected from users of our Sites in connection with their own businesses, including in order to improve their products and services. To learn more about opting out of data collection through Google Analytics, click the links below:

You can withdraw your consent and opt-out of the use of cookies and online tracking at any time by following the links above or you can delete and/or block specific cookies from your browser but some features of the Sites may not function fully or correctly as a result.

You may also be able to limit the association of your mobile device with your online activities by resetting the advertiser ID on your Apple or Android device. For more information about how to change these settings go to:

Apple: http://support.apple.com/kb/HT4228

Android: http://www.google.com/policies/technologies/ads/

The Sites may also offer you the ability to interact with plugins from social media sites like Facebook, in order to allow you to or share your experiences with your online social network. These services collect persistent identifiers through your browser or mobile operating system. If you have previously provided personally identifiable information to third-party sites, that third-party may recognize you here. Your use of social network plugins is subject to each social media site’s privacy policy, which may be different from ours, so please read these policies to assess and understand your options. We have no control over or access to the information that is collected, stored, or used by third-party plugins. If you engage with our content on or through third-party social media sites, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture) to deliver the content or as part of the operation of the plug-in or application. For more information on Facebook’s privacy practices please see .

These Sites are not designed to respond to "do not track" signals received from browsers.

4. How We Use The Information We Collect

We may use the information we obtain to:

– create and manage your account;
– offer and provide products, services and tailored information to you, including email newsletters;
– permit you to participate in blogging, forums, and discussion groups;
– communicate with you about, and administer your participation in, special events, programs, surveys, contests, sweepstakes, and other offers or promotions;
– display content on our Sites, such as stories, product reviews and photos;
– respond to and communicate with you about your requests, questions and comments;
– process claims we receive in connection with our products and services;
– operate, evaluate and improve our business (including developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services and Sites; and performing accounting, auditing, billing, reconciliation and collection activities);
– perform data analyses and other processing (including market and consumer research, and trend analysis);
– protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
– comply with and enforce applicable legal requirements, relevant industry standards and our policies and where otherwise permitted or required by applicable law.

In addition, we use information collected online through cookies, web beacons and other automated means for the purposes described in the Cookies and Online Tracking section above such as: (i) recognizing your computer when you visit the Sites; (ii) tracking you as you navigate the Sites, and to enable the use of any e-commerce facilities; (iii) improving the Sites’ usability; (iv) analyzing the use of the Sites; (v) administration of the Sites; and (vi) personalizing the Sites for you, including targeting content and advertisements which may be of particular interest to you. We also use this information to help diagnose technical and service problems, administer our Sites, identify users of our Sites, and gather demographic information about our users. We use clickstream data to determine how much time users spend on web pages of our Sites, how users navigate through our Sites, and how we may tailor our Sites to better meet the needs of our users. See the Cookies and Online Tracking section above for more information.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

Note to EU Individuals only: Our EU Processing for the above purposes will be on the basis that it is necessary: (i) for our legitimate interests where these do not override your own interests, rights and freedoms and our legitimate interests include the operation of the Sites and our other business activities in an effective and efficient manner in order to publish and promote our products and services, our business and our brand and to provide you with, or to engage with you in order to be able to provide others, with interesting, engaging and appropriate content, events and activities; (ii) to perform a contract we have entered into or are about to enter into with you personally; or (iii) to comply with legal and regulatory requirements and requests. In rare, emergency situations we may use your personal data for your or someone else's vital interests. We generally do not rely on your consent as the basis for our EU Processing other than in relation to: (i) the use of cookies (see the Cookies and Online Tracking section above); and (ii) to send you marketing emails (see the Your Choices section below); and we will inform you specifically when we seek to obtain consent from you as well as your ability to withdraw that consent at any time. In some cases there may be overlap between these different bases. In compliance with the above, please note that we may undertake some EU Processing without your specific knowledge or consent where this is required or permitted by law, but if you would like more information about our EU Processing please us at any time. Unless otherwise required or permitted by law, before we begin EU Processing of your personal data for a purpose unrelated to those above, we will notify you and explain the legal basis which allows us to do so.

5. Information We Share

We may share the information you provide with companies that are related to K through common ownership.

In addition, we may share information about you with non-affiliated third parties whose products or services may be of interest to you. These third parties may you about their products and services. We will not share your information with these third parties for their own marketing purposes if you request that we not do so. See below in the Section titled Your Choices for how to opt-out. We may, however, engage in joint marketing activities with selected third parties and may share personal information about our Site visitors with them.

Note to EU Individuals only and Canadian Individuals only: We do not share your personal data with affiliated or unaffiliated third parties for them to you with email marketing about their products or services or for joint email marketing purposes without having obtained your prior opt-in consent (see the Your Choices section below).

Unless you have opted out, we may also share certain information such as your email address with Facebook, Google, Amazon, Twitter, and other third parties so that we can serve targeted ads and content to you and others with similar interests on such third parties’ respective sites (see the Your Choices section below for more information on how to opt out). These third parties use the data to help target our ads to you and others. This is called custom audiences and matching.

We share personal information with third parties who perform services on our behalf. For example: when you make a purchase, we may share information about you and your transaction with other companies for the purpose of processing your transaction, and we may retain outside companies to manage databases of customer information, to provide advertising services and to distribute e-mail offerings.

Our Sites may feature blogs, forums, discussion groups and comments. Please be aware that some or all of the information you provide (including personally identifiable information) in connection with these activities may be made publicly available.

We or our U.S., Canadian and other service providers also may disclose information about you: (i) if we are permitted or required to do so by law, regulation or legal process (such as in response to a court order or subpoena, which may include lawful access by U.S., Canadian or other foreign governmental authorities, courts or law enforcement agencies); (ii) in response to requests by government agencies, such as law enforcement authorities; or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We reserve the right to transfer any information we have about you in the event of a prospective or completed merger, sale or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, we will provide such entity with this Privacy and Cookie Notice so that they are aware of the terms hereunder.

6. Links to Other Websites

Our Sites may contain links to other websites for your convenience and information. These may include, without limitation, some of the blogs and forums to which you are provided access through the Sites. These websites may be operated by companies not affiliated with us. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of any websites that are not affiliated with K, any use of those websites, or the privacy practices of those websites.

7. Children’s Privacy

The Sites are intended for a general audience of adult readers and is not intended for children. We do not knowingly collect personal information from children under the age of 13 on our Site. We use technical measures intended to prevent the collection of such information from children under 13. If we become aware that we have inadvertently received personal information from a visitor under the age of 13 on our Site, we will delete the information from our records.

Note to EU Individuals only: We do not knowingly conduct EU Processing of the personal data of children in the EU under the age of 16 without parental consent.

8. How We Protect Personal Information

We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We have procedures to deal with any suspected data security breach and will notify you and/or any applicable regulator or supervisory authority or other governmental entity where we are legally required to do so.

Note to EU Individuals only: We provide the Sites and operate our business from the U.S. where the law may not provide the same level of data or privacy protection as your home territory. Where however, we are conducting EU Processing, we will ensure appropriate safeguards are put in place to protect your personal data which give personal data the same protection it has in Europe, as applicable see https://ec.europa.eu/info/law/law-topic/data-protection_en.

9. Your Choices

If you receive a marketing email from us, you can follow the unsubscribe link in each of our e-mail marketing communications to opt-out of receiving the specific type of marketing email (i.e., a particular newsletter) or all marketing emails from Macmillan Trade. Please note that you may continue to receive certain transactional messages from us.

We also give you the option of requesting that K not share your personal information such as your email address with third parties that are unrelated by common ownership with K for marketing use. Click here to send us an e-mail with your name and e-mail address(es) if you DO NOT want us to share your personal information with unrelated third parties for their own marketing use

We also give you the option of requesting that K not use your information for marketing purposes, or share your information with related companies for marketing use. Click here to send us an e-mail with your name and e-mail address(es), if you do not want us to use your information for our marketing purposes, including sharing your email address with third parties to advertise our products on such third party sites by using your email address to create custom audiences and matching, or sharing your information with related companies for marketing use. However, if you send us an opt-out e-mail request, PLEASE NOTE that, unless you indicate to us which of our divisions/senders/entities you would like to opt-out of, you will be opted out of marketing use by all off the U.S. Macmillan Trade entities. That means that you will not receive our e-newsletters or information from us about podcasts, books, promotions, and services.

Please be aware that we are able to effectuate an opt-out only for a specific e-mail address. So, if you have more than one e-mail address or if you have changed your email address, your opt-out request may not be effectuated for any email address that you have not identified in your opt-out request. If you believe you have opted out, but continue to receive e-mails from us, please us by one of the means listed under the How to Contact Us section below, and we will endeavor to resolve the issue.

Note to EU Individuals only: You have legal rights in respect of our EU Processing of personal data, including the right to: (i) request access to the personal data that we hold about you and, in some cases and where technically feasible, you have the right to have your personal data transferred to a third party in a machine-readable format; (ii) ask us to limit or cease using or erase the personal data that we hold about you in certain circumstances and in responding to such requests, we will explain to you the impact of such restrictions or deletions, for example, on our ability to provide all the functions of the Sites to you; (iii) ask us to rectify any inaccurate data we may hold about you - and you can inform of us of any changes to your personal details for us to make; (iv) object to us using your personal data on the basis of our legitimate interests (where relevant) and to ask us not to use your personal data for marketing purposes (so, if you have opted in, you can subsequently withdraw your consent to marketing whether by us or by third parties at any time by clicking the links above ) - see both the How We Use Your Information section and this section above; and (v) lodge a complaint about us to the relevant supervisory authority for personal data, e.g., in the UK this is Information Commissioner’s Office (https://ico.org.uk/). You may action your rights at any time by ing us using the details set out in this Notice and we will comply with your requests unless we have a lawful reason not to do so and within a reasonable period and, in any event, we will respond to you (even if we require an extension of time) within one month of the original request. Prior to meeting such requests, we may require you to confirm your identity by providing approved identification. We will not charge you unless your request is manifestly unfounded or excessive, in which case we may refuse to comply.

10. International Transfers

Please note that any information that you provide to us is being transferred to or collected in the U.S. and U.S. law governs.

BY CONTINUING TO USE THESE SITES AND/OR SUBMITTING YOUR PERSONALLY IDENTIFIABLE INFORMATION, YOU CERTIFY THAT YOU MEET AGE AND OTHER ELIGIBILITY REQUIREMENTS FOR THE SITE AS SET FORTH IN THIS NOTICE AS WELL AS THE TERMS AND CONDITIONS, AND CONSENT TO COLLECTION, USE, DISCLOSURE, STORAGE AND TRANSFER OF YOUR PERSONNALLY IDENTIFIABLE INFORMATION OUTSIDE THE EEA, SWITZERLAND, CANADA, OR ANY OTHER NON U.S. JURISDICTION IN ACCORDANCE WITH THIS NOTICE.

11. Updates To Our Online Privacy Notice

Changes to this Privacy Notice will become effective when those changes are posted to the Sites or otherwise notified to you as required by applicable law. Your continued use of the services and the Sites subsequent to any changes to this Privacy Policy constitutes your acceptance of the changes subject to the contents of the specific notification. We indicate the effective date of this Notice (and any updates) at the top of the Notice.

12. How To Contact Us

If you would like to update your information and/or preferences, click here.

If you would like to request access, update or correct other information in our records in accordance with your rights under applicable law, please us as set out below.

If you have any questions about our information practices (or those of our service providers) or our products or services, please us by: